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r a , <br /> 1 JOHN D. PHILLIPS <br /> District Attorney <br /> 2 San Joaquin County FILED <br /> By: LISA F. BROWN <br /> 3 Deputy District Attorney 1963 JAN 10 2 19 <br /> Environmental Prosecutions Unit � �r _ r, �� � � <br /> 4 P .O. Box 990 -A PH �t�.EPPEiS'N.,C' C ,X <br /> Stockton, CA 95201 p,�q -C9 RHS <br /> 5 E:CATTLE4 <br /> Telephone: (209) 944-3811 <br /> 6 <br /> Attorneys for Plaintiff <br /> 7 <br /> 8 <br /> SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN <br /> 9 <br /> The People of the State of California, ) No. 213232 <br /> 10 ) <br /> Plaintiff , ) DECLARATION OF <br /> 11 ) STEVE ST. SURE IN <br /> V. ) SUPPORT OF RESTRAINING <br /> 12 ) ORDER AND PRELIMINARY <br /> INJUNCTION <br /> 13 F & W CATTLE COMPANY and ) <br /> COMMERCIAL SALVAGE, INC. j <br /> 14 <br /> Defendants ) <br /> 15 <br /> 16 1 . STEVE ST. SURE, declare: <br /> 17 1. I am the Senior Code Enforcement Officer for the San <br /> 18 Joaquin County Department of Planning and Building Inspection. <br /> 19 2. I have personal knowledge of the following facts and am <br /> 20 competent to testify as to the truth of these facts if called as <br /> 21 a witness. <br /> 22 3. On January 6, 1989, I was present at the F & W CATTLE <br /> 23 COMPANY feedlot located at 19051 South McKinly Avenue, Manteca, <br /> 24 California, and observed the following: <br /> 25 a . More than several square yards of hot, steaming coffee <br /> 26 grounds were located in a depression previously used by F & W <br /> 27 CATTLE COMPANY for dumping of coffee grounds. - I took photographs <br /> 28 <br /> 1 . <br />